Last Tuesday,an old client,Mr.Li,called me in a panic.A batch of “industrial cleaning agents” he had imported from Osaka,Japan—though not classified as hazardous chemicals (general chemicals)—had been stuck at the port for five full days.

The reason is both laughable and frustrating: in Section 3 of the MSDS (Material Safety Data Sheet) provided by the Japanese supplier,the critical 5 % active ingredient was labeled “Confidential” to protect trade secrets.To save trouble,the customs broker simply classified the product under “organic surface-active agents (3402)” based on the main component.When customs inspected the shipment,they demanded to know what the 5 % “secret” actually was; the final test revealed it was a controlled organic solvent.As a result,the HS code had to be switched to Chapter 38 and a Dual-Use Items License had to be applied for retroactively.

This delay not only incurred detention charges of tens of thousands of yuan,but also nearly forced Mr.Li’s factory to shut down.This caseSuch circles are hardly uncommon—For chemicals imported from Japan,“general chemicals” does not mean “general treatment.”

I.Why does the general classification of Japanese Buddhist music so often “crash and burn”?

Japanese chemical companies are renowned for their rigor,yet equally famous for “ingredient secrecy.” In import practice,the core basis for customs classification (HS Code) isIngredient content (CAS No.) and principle of use.The contradiction between these two constitutes the greatest pain point.

The table below illustrates typical conflicts between the documentation provided by Japanese suppliers and the declaration requirements of China Customs:

II.Practical Guidelines for Customs Classification of Generic Products (SOP)

In response to the strict review of "consistent documentation" for chemical products by customs in 2025,the following is a set of standardized import classification and declaration processes.

Step 1: Through-component audit (1–2 weeks before shipment)

Output:

Before signing the Purchase Order (PO),the manufacturer’s official document must be obtained.100% Ingredient List(If it is a confidential formula,the manufacturer must issue a separate "Confidentiality Letter of Ingredients" to the customs broker for filing,instead of writing it directly on the customs declaration form).

• CoreAction:CheckeveryingredientCASnumber.
• Thewatershedofcategorical-logicdetermination:
  • Singlecomponent(purity≥95%):UsuallyclassifiedunderChapter28(Inorganicchemicals)orChapter29(Organicchemicals).
    • Forexample,high-purityethyleneglycolimportedfromJapanisclassifiedunder2905.3100.
  • Mixture (formulation): Usually byFunction / Purposeare classified into Chapters 32–38.
    • Forexample,acleaningsolutionmadebymixingethyleneglycolwithsurfactantsisclassifiedunder3402(detergents)or3824(otherchemicalproductsnotelsewherespecified).

Step 2: Determine the HS Code and Regulatory Conditions

Output:

After determining the HS code based on composition and intended use,pay special attention to the following three classification principles that are easily confused:

• Chapter32(Dyes/Paints)vs.Chapter39(Polymers):
  • Iftheproductisapolymerandcontainssolvent,itisusuallyclassifiedunderChapter32whenthesolventcontentis>50%;ifthesolventis50%,itmayfallunderChapter39(plasticsinprimaryforms).High-performanceresinliquidsimportedintoJapanoftengetmisclassifiedhere.
• Chapter 34 (Cleaning Agents) vs.Chapter 38 (Solvents):
  • Iftheproductmainlyremovesdirtthrough“surface-activeaction,”classifyitunder3402.
  • Iftheprimarymethodofstainremovalis"dissolution"(e.g.containingalcoholoracetone),itisclassifiedunder3814(organiccompositesolvents).Taxratesandexcisedutiesdiffersignificantly.
• Hazard-related screening (Critical):
  • Evenifthemanufacturerclaimsit’s"non-hazardous,"youstillneedtocheckSection9oftheMSDS.FlashPointIftheclosed-cupflashpointis≤60°C,evenifdeclaredasgeneralchemicals,customswillmostlikelyrequireinspectionashazardousgoods.

Step 3: Document Preparation and Declaration Elements (Coordination under FOB/CIF Terms)

Output:

When preparing the Packing List and Invoice,please refer to the table below:

III.Expert Pitfalls to Avoid

As a customs consultant who has handled China–Japan chemical trade for years,I have three “blood-and-tears recommendations”:

• Bewareof“mixtures”turninginto“compounds”:

Japanese craftsmanship is meticulous: a compound is often dissolved in water for transport.For example,a “50 % aqueous solution of sodium hydroxide” is still classified under “sodium hydroxide (2815),” not as a mixture.Water is generally regarded as a carrier and does not alter the classification attributes.

Japanese invoices often list only trade names (e.g.“CleanHelper A-100”).Never declare just that!You must give the standard chemical designation (e.g.“industrial cleaning preparation containing non-ionic surfactants”).Customs’ risk-assessment system flags non-standard product names at a very high rate.

If the imported goods are paints/coatings under HS codes 3208 or 3209,no matter the quantity,filing must be applied for two months before arrival.Many enterprises only realize after the goods arrive that no filing was done and have no choice but to return them,because the filing cycle takes as long as 45 days.

IV.Immediate Action List

If your shipment is about to depart from Japan,please immediately verify the following four points:

Request the authentic CAS Number: Even if an NDA has to be signed,we still need to obtain the actual CAS number of the ingredient listed as “Others” in the MSDS for pre-classification.

Check the flash-point data: Check Section 9 of the MSDS for physicochemical properties and confirm whether the flash point is above 60 °C.If it is below 60 °C,immediately follow the hazardous-chemical procedure; do not take chances and declare it as an ordinary chemical.

Prepare Chinese labels: Prepare the Chinese label PDF in advance and send it to the Japanese shipper,requiring them to print and affix it to each drum/bottle before shipment.

Confirm wooden packaging: Japanese exports often use wooden pallets; you must verify that the pallets bear the IPPC fumigation mark,or customs clearance in China will be impossible.